Effective Date: 29 October 2026
I. Data Processing in General
Controller and Contact
The controller responsible for the processing of personal data on this website is:
Prosecco 37 d.o.o. Igriška ulica 5 1000 Ljubljana Slovenia VAT ID: SI72261536 Email: privacy@prosecco37.com
We have not appointed a Data Protection Officer (DPO), as we do not meet the threshold that requires one. Privacy matters are handled by our Chief Information Security Officer (CISO), who can be reached at privacy@prosecco37.com.
Scope of the Processing of Personal Data
The processing of personal data is limited to data that is required to operate a functional website and for the provision of content and services. The processing of personal data of our users is based on the purposes agreed or on a legal basis (GDPR). We only collect personal data that is necessary to implement and process our tasks and services or if you provide data voluntarily.
Your Rights
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you, or if you want it to be removed from our systems, please contact us at privacy@prosecco37.com.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification.
- The right to object.
- The right of restriction.
- The right to data portability.
- The right to withdraw consent.
If you believe that the processing of your personal data is inconsistent with or contradicts the applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority. In Slovenia this is the Informacijski pooblaščenec (Information Commissioner), ip-rs.si.
II. Description and Scope of Data Processing
Provision of the Website
Our website is a static informational website. It is served through a content delivery network and does not use analytics, tracking, advertising, or profiling tools. We do not create user profiles and we do not evaluate your behaviour on this website.
Like any website, serving pages technically requires the processing of certain connection data. The following data may be recorded in standard, necessary access logs:
- Information regarding the type and version of internet browser used to access the website
- IP address (anonymised — last octet zeroed)
- Date and time of each access
- Web page from which the user was redirected to our page
These logs are used solely to operate and secure the website (availability, error diagnosis and abuse prevention). They are not used for analytics or marketing, are not merged with other personal data sources, and are not disclosed to third parties beyond our hosting and content delivery provider. Logs are retained for 3 days and then automatically deleted.
Legal basis for the temporary storage of data and log files is Article 6 (1) (f) GDPR (legitimate interests in operating a secure and available website).
Cookies
This website does not use cookies for analytics, advertising, or tracking, and does not set any non-essential cookies. Only strictly necessary technical storage may be used to deliver the website.
You can configure your browser to block or delete cookies at any time. Please note that blocking strictly necessary cookies may affect how the website functions.
Legal basis for the processing of data through strictly necessary cookies, where applicable, is Article 6 (1) (f) GDPR.
Contact
If you contact us by email or another form of electronic message, your data will only be used to process your inquiry and possible further questions you might have. We do not operate a contact form that stores submissions on this website; contact is made by email.
Legal basis for the processing of your inquiry is Article 6 (1) (b) GDPR where the inquiry relates to a contract or pre-contractual steps, and otherwise Article 6 (1) (f) GDPR (legitimate interest in responding to enquiries).
Enquiries are received and handled using Microsoft 365 (email).
Products and Product Data
Our products (CAP and Anonymizator) involve separate processing activities, including where we act as a processor on behalf of our customers. Those activities are described in the product privacy notice provided during registration and in our record of processing activities, and are not covered by this website privacy policy.
III. Data Security
We use HTTPS protocol in connection with the highest encryption levels that are supported by your browser. If a page on our website was/is being transmitted encrypted it is shown by the lock symbol in the address bar of your browser.
Additionally, we use appropriate technical and organizational security measures to protect your data from accidental or intentional manipulation, partial or complete loss, destruction, or to prevent unauthorized access by third parties. Our security measures are continuously upgraded according to the latest technological developments.
The website is hosted and delivered using Bunny.net (content delivery network and edge storage). Data is processed within the European Economic Area.
Disclosure to Third Parties
We do not sell personal data. We share data only with service providers that are necessary to operate this website and to communicate with you, and only to the extent required:
- Bunny.net — content delivery network and edge storage (website hosting and delivery)
- Microsoft 365 — email (handling enquiries sent to us)
These providers process data on our behalf under applicable data protection agreements. We do not use Google Analytics, Hotjar, HubSpot, or similar analytics, tracking, or marketing services on this website.
IV. Modifications and Additions to This Privacy Policy
We try to keep this privacy policy up to date at all times in accordance with the development of our platforms. We reserve the right to make changes to this policy at any time. You can see the effective date at the top.
V. Acceptance
By using our website, you acknowledge that you have read this Privacy Policy. The legal basis for each processing activity is set out in Section II; none of the processing described in this policy relies on consent.
Contact Information
If you have any questions about this Privacy Policy, please contact us:
Prosecco 37 d.o.o. Igriška ulica 5 1000 Ljubljana Slovenia VAT ID: SI72261536
Email: privacy@prosecco37.com